As a result of COVID-19 all of us in social care have had to be adaptable and find different ways of delivering services. This has also been true for CQC who have also had to change and review how they regulate and monitor services. It has had to provide a more remote, ‘arm’s length’ service and relied more upon what people have told them about the quality of services, and review how they make judgements and what action they should take.
These changes were seen initially in their ‘Emergency Support Framework’ and more recently in the delivery of the ‘Transitional Monitoring Approach’. As a result, we are all used to the fact that there have been less site visits to services, more remote contact to ask for information about progress and quality and a different kind of relationship with CQC being established.
But do we think this is going to be a temporary shift? Looking at the new CQC strategy, it seems that this more distant approach is here to stay, albeit with more robust processes being developed to provide assurance of the quality of services.
What is the new CQC strategy?
Indeed, the new CQC strategy, which can be found here, has four main themes, all of which have incorporated and learnt from the pandemic, rather than carrying on as before and ignoring the implications of such a major event.
The four themes are:
- People and communities
- Smarter regulation
- Safety through learning
- Accelerating improvement
These ‘themes’ have been used as a springboard, and to frame the thinking about what an inspection will involve, and how the evidence will be gathered to support decision making. The CQC need to ensure that the processes are practical for social care, support the strategy and deliver on their requirements of being a regulator.
What may remain the same?
So, what do we think the new assessment framework will look like?
CQC has been consulting and asking people for their views on what they have proposed as a way forward, but to date we haven’t had a definitive answer to what the future will look like for social care services. But we have a good idea, and we can share with you what we know, so you can be prepared and start to think about what you will need to do to be ready when the changes ‘go live’.
Firstly, it might be useful to start off with what we think won’t change. The CQC is committed to the ‘5 questions’ (safe, effective caring, responsive and well led), and indeed are looking at hardwiring them into health and social care and using the same definitions for all services – so the overarching meaning of safe will be same for a hospital, GP practice, dentist or a small care home.
However, it looks like they will be more focused on what is important to the individual using services and will be phrased as ‘I’ statements and state what is important to the individual using services. It also looks like ratings will remain with the four levels (outstanding, good, requires improvement and inadequate) still being used, although there may be more of a ‘floating scale’ and an opportunity to be rated at a position along the spectrum of each of the four rating levels dependent upon the evidence gathered. This is still just an idea with CQC, and I see it being fraught with difficulty and open to challenge.
It must also be stated that it looks like the inspection framework will be similar to what it is now, with the CQC evolving the way it works in response to their learning over the last six years, and in particular from the impact of the pandemic. It does not appear the regulator is going to rip up current thinking and start again, the system and ways of working will still be very recognisable
Goodbye to KLOEs?
Ok, enough of what isn’t changing, let’s move on to what we think will be different.
The Key Lines of Enquiry (KLOEs) may well be changing, and the latest information indicates that they will be called ‘Quality Statements’, the areas covered are like the current ones, but the number has been expanded by about 30%, with a proposed 36 ‘Quality Statements’. This increase is most notable under the Well-led, Caring and Effective questions.
It appears that there is going to be more emphasis on the individual receiving services and how their lives are supported by the provider with more questions about respect, dignity, fairness, equality and how services work together for the benefit of the person. It is also proposed that there will be more of a spotlight on the management and ownership of the service with CQC increasingly looking at the service’s vision, governance, culture, engagement, improvement, capacity, and capability.
The way in which evidence is gathered by CQC to come to a judgement is also going to be more objective and uniform with six processes used across the Quality Statements. It has been suggested that these are:
- What is people’s experience?
- What do staff and leaders tell us?
- What have we heard from our partners?
- What have we observed?
- What do we know from the organisation’s processes?
- What can we learn from the outcomes and performance data?
Will ratings change?
As can be seen, most of this information can be gathered remotely, without the need for a site visit, and the intention is that site visits, or traditional inspections, will only take place when evidence cannot be found through analysis of received information from the local authority, professionals, notifications, PIR, surveys and so on.
Site visits will also take place when the CQC thinks there is a risk at the service that can only be assessed by observing practice and having face to face discussions.
As such, the current expectation of receiving a site visit at a frequency dictated by the rating will not continue. It is understood that there will need to be a further explanation of how this will work, and how ratings will change, but there is a strong feeling that ratings may be able to be changed without a site visit, but again this is just speculation at this stage and no firm decisions have been made by CQC. It is a question of ‘watch this space’.
It is proposed that there will be a third level of information to support decision making by CQC, and that these will be called ‘Quality Descriptors’, these will be similar to the current ‘characteristics of ratings’ and will outline for the types of services what would be expected to be seen for the individual ‘Quality Statements’ and will support decisions about ratings. There has been little information shared about what these might look like but be assured we will share this with you when we know more.
CQC has already started this modernisation process, and you will start to see a monthly ‘public statement’ for each service that indicates that nothing has changed at the service and CQC are satisfied with the quality. The decision to publish this statement is based upon information received about the service in the previous month, and an internal analysis of the implications of the information received. However, if the information received indicated a change at the service, that has increased the risk this may stimulate an actual site visit, for example an excess number of notifications, safeguarding alerts, COVID-19 or a manager leaving will all affect the CQC view of the stability and quality of the service.
What can you do now?
As you can read there are still a lot of unknowns, and CQC need to add ‘more colour’ to the picture so we all know what to do. The latest timeframe given by CQC on when changes will be implemented is very vague with 2022 being mentioned, but no month or phased roll out being indicated at this stage. However, it is a given that things will change, and in fact have changed, so we should be on the front foot and anticipate changes so we can all be better prepared.
I would advise that as a manager of a service you should:
- Sign up to newsletters, alerts, and other information from CQC, and contribute to their consultations. If you don’t make your views known you can’t really blame CQC for doing what they think is best.
- Have evidence of how you have involved people that use services in changes you have made.
- Ensure that staff are included and can contribute to any changes, take them with you on the journey and try not to do things ‘to them’, but do it ‘with them’.
- Develop open and trusting relationships with the local authority and health partners. And again, have evidence to support this.
- Keep your CQC evidence file organised and up to date, so you have it to hand when needed. If you haven’t got one, develop one based on the current KLOEs and include for each one the evidence you have, and where it is located.
- Make sure you develop a positive relationship with CQC and share information with them – including innovative practice, so they know what you are doing and how proactive you are.
- Use the QCS system as much as possible, share information and encourage staff to use the app.
- Make sure you do all the audits and quality assurance that you need to do. This way you can evidence that you are managing the quality of the service being provided.
I hope this article provides you with a ‘heads up’ of what may be coming from CQC in the future and gives you some practical things that you can do now to prepare. Also, please keep looking at the QCS system for the latest information and updates as we will always let you know when change is coming and adapt the system to reflect the changes to support you to continue to deliver outstanding care.